995 resultados para Taxation, State.
Taxation of multinational banks : using formulary apportionment to reflect economic reality (Part 2)
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As stated in Part 1 of this article, formulary appointment does not attempt to undertake a transactional division of a highly integrated multinational entity; rather, it allocates income to the jurisdictions based on economically justifiable formula. This article argues that the unitary taxation model is superior to the current arms-lenght model for the taxation of multinational banks despite significant implementation, complicance and enforcement issues. Part one of the article gave some background on the taxation of multinational banks, followed by a discussion of their uniqueness, and the theoretical benefits of the unitary tax model for multinational banking. Part 2 below covers the practical implications of accepting formulary apportionment as an 'optimal' regime for taxing multinational banks.
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This article argues that multinational banks have characteristics which are unique and distinguishable from traditional multinational entities. The first distinguishing feature is the unique nature of the services and consequent products supplied by multinational banks, which are aimed at meeting client global demand. The second distinguishing feature is the non-traditional organisational structure that is adopted. This structure, also designed to meet client global demand, introduces issues previously not recognised in the traditional taxation system, which is designed for the structure of traditional multinational entities. The unique differences between traditional multinational entities and multinational banks means there may be the need for a distinct international tax regime. It is argued that there are “outmoded economic assumptions” upon which the present tax laws relating to multinational banks are based. An examination of the unique nature of multinational banks leads to the conclusion that the appropriate tax treatment of these banks is different from the appropriate tax treatment of multinational entities generally.
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As 2001 was the International Year of the Volunteer as it seemed timely to look at the legal, social and political frameworks which provide for the long term growth of volunteers. The focus of this research is on the nature and extent of volunteers in the Queensland State Government. The social capital debate (expanded by Robert Putnam in 1995) is about citizens’ participation in extracurricular activities and has been extended to mean a collective intelligence – a capacity as a people to create the society we want. The volunteer phenomenon has been used to indicate social and ethical concern.
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Covers the fundamental principles of the Australian tax system, providing students with guidance on reading and using tax resources such as legislation, case law and Australian Taxation Office rulings -- Back cover.
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"With its clear and concise explanations of taxation law concepts, Principles of Taxation Law 2009 is the ideal text for students studying this complex subject. It covers all major topics underpinning the Australian tax system, including income, deductions, capital gains, tax accounting, international issues, fringe benefits, tax administration, goods and services tax and, in this new edition, offsets and superannuation. Importantly, the book commences with a special chapter on how to study tax law and succeed in taxation law exams."--Publisher description.
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A novel concept of producing high dc voltage for pulsed-power applications is proposed in this paper. The topology consists of an LC resonant circuit supplied through a tuned alternating waveform that is produced by an inverter. The control scheme is based on the detection of variations in the resonant frequency and adjustment of the switching signal patterns for the inverter to produce a square waveform with exactly the same frequencies. Therefore the capacitor voltage oscillates divergently with an increasing amplitude. A simple one-stage capacitor-diode voltage multiplier (CDVM) connected to the resonant capacitor then rectifies the alternating voltage and gives a dc level equal to twice the input voltage amplitude. The produced high voltage appears then in the form of high-voltage pulses across the load. A basic model is simulated by Simulink platform of MATLAB and the results are included in the paper.
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Taxation law can be an incredibly complex subject to absorb, particularly when time is limited. Written specifically for students, Principles of Taxation Law 2011 brings much needed clarity to this area of law -- Back cover.
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In light of McDermott Industries (AUST) Pty Ltd v Commissioner of Taxation, and Draft Taxation Ruling TR 2006/D8, this article considers the current Australian taxation position of profits arising from the cross-border leasing of vessels in the maritime industry. It focuses on the tax treaties to which Australia is a party, in particular the application of the business profits provisions of those treaties, and the deemed existence of a permanent establishment where substantial equipment, owned by a fiscal non-resident, is used within Australian waters.
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In 1995, the Federal Commissioner of Taxation released Taxation Ruling TR 95/35 in an attempt to comprehensively address the appropriate capital gains tax treatment of a receipt of compensation, awarded either by the courts or via a settlement. The ruling was in response to the numerous, somewhat contradictory, court decisions of the early 1990s. Despite the release of TR 95/35, there still appears to be a lack of consensus as to the appropriate treatment of such awards. It has been suggested that the only way a taxpayer can, with any certainty, determine their liability is to obtain a private binding ruling, a far from satisfactory situation. In an attempt to clarify what the capital gains tax consequences of a compensation receipt should be, this article examines the Australian position and explores the comparative jurisprudence of the United Kingdom and Canada to ascertain whether the Australian attitude is consistent with these international jurisdictions. This article concludes that while the jurisdictions, through differing approaches, achieve a similar result, there is still a need to address the uncertainties that remain.
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'A Simple Plan' is a deceptively complex and multilayered film, combining elements of Celtic mythology with the morality play and the windfall fantasy gone disastrously wrong. Despite its blending of realism and heavyhanded symbolism, and its abundant trans-textual gestures, 'A Simple Plan' is in many ways defiantly not a 90s movie: its leading characters are fashionably flawed, but they are neither sensitive, nor honourable, nor heroic; there are no startling special effects or intricate timeshifts; and it desperately gives the impression of depth, of being emphatically more than mere superficial excess. At a stretch it almost appears to be a throwback to the 1930s Production Code emphasis on the role of cinema in moral instruction; while good hardly triumphs over evil, venality is painfully and emphatically punished. But in other ways it is a quintessential late 90s film: an American/British/Japanese/German/French co-production, 'A Simple Plan' acts most palpably as a commentary on the moral, economic and social condition of the United States at the end of the American century.
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Unitary taxation is the taxation of the worldwide income of a multinational enterprise (MNE) and is normally based on a formulary apportionment method, which allocates income to the relevant jurisdictions based on a percentage of the MNE's world-wide profits. The unitary taxation model has several advantages over the existing arm's length model: 1. Where MNEs are highly integrated, unitary taxation has greater consistency with economic reality. 2. Greater certainty is provided to taxpayers. 3. Unitary taxation conforms to the aim of efficient operations within the MNE. 4. The aim of unitary taxation, to find an equitable split of profits between the jurisdictions, should ultimately be the overall aim of any tax regime. The advantages and disadvantages associated with the adoption of a unitary taxation model through the implementation of a formulary apportionment approach to the taxation of MNEs are examined.
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Background Screening tests of basic cognitive status or ‘mental state have been shown to predict mortality and functional outcomes in adults. This study examined the relationship between mental state and outcomes in children with type 1 diabetes. Objective We aimed to determine whether mental state at diagnosis predicts longer term cognitive function of children with a new diagnosis of type 1 diabetes. Methods Mental state of 87 patients presenting with newly diagnosed type 1 diabetes was assessed using the School-Years Screening Test for the Evaluation of Mental Status. Cognitive abilities were assessed 1 wk and 6 months postdiagnosis using standardized tests of attention, memory, and intelligence. Results Thirty-seven children (42.5%) had reduced mental state at diagnosis. Children with impaired mental state had poorer attention and memory in the week following diagnosis, and, after controlling for possible confounding factors, significantly lower IQ at 6 months compared to those with unimpaired mental state (p < 0.05). Conclusions Cognition is impaired acutely in a significant number of children presenting with newly diagnosed type 1 diabetes. Mental state screening is an effective method of identifying children at risk of ongoing cognitive difficulties in the days and months following diagnosis. Clinicians may consider mental state screening for all newly diagnosed diabetic children to identify those at risk of cognitive sequelae.
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This paper presents an analysis of the stream cipher Mixer, a bit-based cipher with structural components similar to the well-known Grain cipher and the LILI family of keystream generators. Mixer uses a 128-bit key and 64-bit IV to initialise a 217-bit internal state. The analysis is focused on the initialisation function of Mixer and shows that there exist multiple key-IV pairs which, after initialisation, produce the same initial state, and consequently will generate the same keystream. Furthermore, if the number of iterations of the state update function performed during initialisation is increased, then the number of distinct initial states that can be obtained decreases. It is also shown that there exist some distinct initial states which produce the same keystream, resulting in a further reduction of the effective key space
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There is a tax amendment bill which will be debated. The Government has promised to outline its plan for the reform of the taxation system sometime this year. The plans appear to go beyond the mere introduction of some sort of goods and services tax to reform of the whole taxation system including fiscal relations with the States. Not for profit organisations will find their taxation environment will change. Governments are reluctant to permit exemptions to a GST style arrangements. GST trade offs such as reduced income tax rates and abolishing indirect taxes are useless to nonprofit organisations, as many are already exempt from such imposts. Administrative changes to tax collections may also have an impact. If the government decides to make an individual PAYE taxpayer return optional in exchange for no or standard deductions, this may have an effect on fundraising. The FBT and salary packaging schemes that not for profit organisations use will be under intense scrutiny. A regionalisation of the ATO along the successful model of the ASC would see discrete areas such as not for profit exemptions being centralised in one regional office for the whole of Australia. For example the Tasmanian ASC Office has the responsibility for much work in respect of corporate charities and not for profit companies.